Thursday, April 12, 2007

SAY NO TO IRRADIATED FOODS – REQUIRE LABELING!
By Neil E. Levin, CCN, DANLA
I do not want to eat irradiated foods. I should be able to obtain information on how my food is produced and processed so that I can make educated dietary choices, as is my right. But the FDA wants to allow irradiated foods to be labeled as “pasteurized”, without requiring them to bear the irradiation symbol (the radura logo). That would eliminate my ability to ‘vote with my pocketbook’ by making informed choices.
If there is a demonstrated benefit to eating irradiated foods that outweighs the known and suspected risks, let the manufacturers sell us on the safety and benefit of their products, using the free market. If they can convince us that there are benefits, then the irradiation symbol will be a positive in the marketplace. If not, if may be a negative. But that’s up to them to make their best case. At least that would be true in a free market, if we were told which foods are irradiated and why.
By allowing manufacturers to hide their questionable practices (whether irradiation, chemicals or genetic engineering) the FDA is artificially subsidizing businesses at the expense of consumers’ freedom of choice. That is not free market economics and eliminates any possibility of consumers being able to make their own decisions. We deserve more respect.
Moreover, there are known, detectable changes to foods treated with radiation, making them measurably different from all other foods (see the quotes and references below). This proves that the FDA’s proposal of labeling them as merely “pasteurized” is actually misleading.
Send your comments to the FDA to insist that irradiated foods be labeled, since they are clearly different from other foods. You can do this at:
http://www.accessdata.fda.gov/scripts/oc/dockets/comments/getDocketInfo.cfm?EC_DOCUMENT_ID=1511&SORT=&MAXROWS=15&START=46&CID=&AGENCY=FDA
REFERENCES:
“The 2-alkylcyclobutanones (2-ACBs) are formed from triglycerides by irradiation treatment and may be used as markers for this type of food processing.” (Horvatovich P, et al. Determination of monounsaturated alkyl side chain 2-alkylcyclobutanones in irradiated foods. J Agric Food Chem. 2005 Jul 27;53(15):5836-41. PMID: 16028962)
“Both the free radicals and the alkylcyclobutanones were found to increase with irradiation dose. In general, linear relationships between the amount of radicals and irradiation dosage could be established.” (Sin DW, Wong YC, Yao WY. Analysis of gamma-irradiated melon, pumpkin, and sunflower seeds by electron paramagnetic resonance spectroscopy and gas chromatography-mass spectrometry. J Agric Food Chem. 2006 Sep 20;54(19):7159-66. PMID: 16968077)
“The irradiation of fat results in the formation of 2-alkylcyclobutanones, a new class of food contaminants. Results of previous in vitro studies with primary human colon cells and in vivo experiments with rats fed with 2-alkylcyclobutanones indicated that these radiolytic derivatives may be genotoxic and enhance the progression of colon tumors…In summary, 2dDCB [2-dodecylcyclobutanone] was clearly genotoxic in healthy human colon epithelial cells and in cells representing preneoplastic colon adenoma. These findings provide additional evidence that this compound may be regarded as a possible risk factor for processes in colon carcinogenesis related to initiation and progression.” (Knoll N, et al. 2-Dodecylcyclobutanone, a radiolytic product of palmitic acid, is genotoxic in primary human colon cells and in cells from preneoplastic lesions. Mutat Res. 2006 Feb 22;594(1-2):10-9. Epub 2005 Sep 8. PMID: 16153665)
“Alkylcyclobutanones (2-ACBs) are suspected cancer promoters and clastogens, which have raised concerns about the safety of irradiated foods.” (Gadgil P, Smith JS. Metabolism by rats of 2-dodecylcyclobutanone, a radiolytic compound present in irradiated beef. J Agric Food Chem. 2006 Jun 28;54(13):4896-900. PMID: 16787045)
“This is the first demonstration that a compound found exclusively in irradiated dietary fats may promote colon carcinogenesis in animals treated with a chemical carcinogen.” (Raul F, et al. Food-borne radiolytic compounds (2-alkylcyclobutanones) may promote experimental colon carcinogenesis. Nutr Cancer. 2002;44(2):189-91. PMID: 12734067)

Regarding:
Guidance for Industry on Complementary and Alternative Medicine Products and Their Regulation by the Food and Drug Administration
http://www.fda.gov/OHRMS/DOCKETS/98fr/06d-0480-gld0001.pdf
This proposal is in a public comment period. I believe that it goes too far in re-classifying natural products as drugs based solely on practitioner claims.
While the concept of the FDA determining which regulations certain products or procedures fall into seems reasonable, the agency's attitude that they can call a vegetable juice product a drug just because someone suggests using it to treat a disease should be considered unreasonable.
The FDA already has the power to regulate drug claims, but not to treat a food (including dietary supplements) or cosmetic item as a drug simply because of an unapproved claim or use. In other words, the act of claiming that a product can treat a disease is already regulated under current laws concerning drug claims on product labels or advertising. It is too confusing and illogical to treat an individual product sometimes as a food and sometimes as a drug, varying with the label claim, especially when the drug claim is already illegal.
The FDA's given example of cranberries, which do have a biological function of helping to inhibit the implantation of new bacterial colonies in the urinary tract but do not actually remove existing colonies, is very misleading. Cranberries cannot be used to treat an existing infection, though it may aid the body in managing urinary tract health. The unapproved (and inaccurate) disease claim is already prohibited under current law (DSHEA), yet the FDA now proposes to regulate illegally labeled cranberry products as drugs if someone does make this illegal claim!
The FDA did not propose that foods or dietary supplements be generally regulated as drugs and only be available by prescription. The agency is actually trying to prevent doctors from making drug claims for supplements and foods. Yet physicians can currently make off-label prescriptions for drugs! The distinction is artificial, and the drugs are the more dangerous products by far!
Concerned citizens are encouraged to submit their own comments by the end of the month. I suggest stressing your strong support for health freedom, which includes the ability to freely access CAM services and products (including dietary supplements) without undue government interference. You may also wish to support CAM practitioners' ability to prescribe natural products without the FDA treating them as unapproved drugs.
If the agency applies this same logic to other CAM modalities, the FDA's proposed enforcement of current regulations on licensed, credentialed health practitioners would be a disaster. The comment period ends May 29, 2007.
Please send your comments to the FDA to oppose this new power grab:
http://www.accessdata.fda.gov/scripts/oc/dockets/comments/COMMENTSMain.CFM?EC_DOCUMENT_ID=1451&SUBTYP=CONTINUE&CID=&AGENCY=FDA

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About Me

Neil E. Levin, CCN, DANLA is a nationally board-certified clinical nutritionist with a Diplomate in Advanced Nutritional Laboratory Assessment. He is a professional member of the International & American Associations of Clinical Nutritionists.
Neil is a nutrition educator and a dietary supplement formulator.
Neil is a member of the Scientific Council of the national Clinical Nutrition Certification Board and is on the board of directors of the Mid-American Health Organization (MAHO), the Midwest regional affiliate of the National Products Association (NPA). In July, 2008, Neil was named an NPA Industry Champion, "an award given to people who have made notable individual contributions to industry above and beyond what is expected to achieve commercial success".
Neil is the immediate past president and Program Chair of the American Nutrition Association (americannutritionassociation.org).
Neil is frequently published or quoted in magazines, newspapers, and scientific journals and has been on numerous radio and television news programs. Follow me on Twitter: neilelevin